Digitally Coordinate with PHMSA and External Pipeline Stakeholders Posted on September 25, 2020 Learn how you can bridge your PHMSA compliance gaps and introduce new value to your pipeline integrity management in our Achieving PHMSA Compliance in the New Digital Era Webinar In last week’s article on the PHMSA Mega Rule, we discussed the complete record overhauls and numerous additional inspections operators will need to take on as a result of these wide-reaching new rules – and how aerial data is poised to help. However, with the implementation of the Mega Rule, PHMSA isn’t showing signs of slowing pace. With the recent proposal of new rules and amendments to Part 190 and Part 194, PHMSA is looking to shift how pipeline operators interact with regulatory authorities – through digital technology. In this article, we’ll examine what the implications of these new rules are, what opportunities they present for pipeline operators, and why aerial data platforms are the perfect technology to drive this digital shift. PHMSA Wants to Innovate Reporting and Recordkeeping Pipeline operators are required to submit records, create reports and provide certain info to PHMSA staff during routine evaluations and incident investigations. Historically, this process has been a lengthy and laborious service process of providing specific document copies as requests trickle in. After lobbying by operators, PHMSA is recognizing the value of technological innovation, amending Part 190 – Pipeline Safety Enforcement and Regulatory Procedures to allow for use of online portals in information sharing.1 The form this portal takes is largely up to you. PHMSA’s proposed rules only require compliance with a minimum set of ease-of-use standards: Ability to search, download and print operator records through the portal without redacting or altering the document Do not remove document functionality that is available to operator Has a point of contact who can work with PHMSA for addressing technical issues that may arise on the system This new form of digital collaboration can make your dealings with PHMSA a more cost-effective and less time-consuming affair. Aerial data platforms are the technology you should choose to make this transition. Combining advanced AI-driven data analytics, Unmanned Aerial Vehicle (UAV) data sourcing, and visual GIS-based interfaces – the right platform provides the perfect portal for you to work together with PHMSA. This is especially true given new allowances for the use of digital modelling in integrity management planning. Digital Data is Becoming Essential to Facility Response Plans PHMSA is not only embracing the power of digital in recordkeeping, but also in the data that’s used to inform these records. Operators of pipeline facilities that can cause substantial environmental harm to navigable waters or adjoining shorelines are required to prepare facility response plans (FRPs) for worst-case oil discharges (WCDs). With the proposed amendments to Part 194 – Response Plans for Onshore Oil Pipelines, PHMSA is allowing the use of digital-driven methods to inform these FRPS, such as the use of geospatial spill modeling in the estimation of WCDs.2 Aerial data platforms can generate the Digital Elevation Models (DEMs) you need to do just that. From UAV imagery of a pipeline ROW and the surrounding area, photogrammetric mapping techniques can be applied to calculate the ground surface elevations of the environment. From the resulting 3D model, you can calculate how oil spills will affect the surrounding environment based on flow path and rate from the failure source – and how a spill would likely progress toward damage to nearby bodies of water. Pipeline Inspection Data That’s Worth a Thousand Words This is just the beginning of what aerial data has to offer. Because of the open-ended nature of PHMSA’s portal guidelines, you can be proactive in what you implement to smooth coordination efforts. Aerial data platforms provide a unique opportunity to craft a holistic GIS-based interface that PHMSA staff can use to get a complete picture of your integrity management efforts: Right-of-Way Orthomosaics: An ortho stitched together from high-resolution UAV serves as a pristine digital record of your property Annotated Anomalies: Using AI-driven computer vision analysis, aerial data platforms can flag actionable midstream pipeline hazards. Depending on the nature of issue or incident, relevant documentation can be appended for review. Change Detection Timeline: A change detection system compares new and historical inspection data to log subtle changes happening on your ROW. This analysis can play a vital role in monitoring active failures or remediation efforts for reporting to PHMSA authorities. These advantages will make it easy for PHMSA to examine your asset’s history and incidents that they are following-up on. As this technology continues to see adoption across the industry, it may not be long before these visual insights become key components of regulatory compliance. Improve Coordination with External Pipeline Stakeholders The straightforward nature of aerial data makes it the perfect medium for coordinating with external stakeholders beyond just PHMSA: Engage Local Actors: Be it a local government or business, a crystal-clear picture of a potential pipeline hazard can serve as compelling material to spur remedial action. Whether it’s a construction company that you want to take extra-special care to avoid encroachment, or unauthorized third-party activity on your ROW that local authorities can help to mitigate, aerial data makes it easy to pinpoint and illustrate issues you need assistance with. Inform Landowners: It’s better to prevent a landowner issue than find yourself in the middle of one. With aerial data that precisely maps pipeline activity, you can ensure that you and a landowner are on the same page before, during and after construction. Mitigate Litigation: For most pipeline operators, litigation isn’t about “if”, but “when”. By providing stakeholders with a visual timeline and historical project snapshots, companies can avoid wasting time and money on legal issues. A Single Source of Truth for Pipeline Integrity Management By adopting a digital portal approach and leveraging a new visual layer of aerial data, you can enable smoother collaboration with PHMSA than ever before. While new rulemakings tend to be viewed with pessimism and resignation, the technological innovation that PHMSA is encouraging pipeline operators to make stands to deliver massive value for the industry and society at large. And remember, while this article solely focuses on how you can leverage aerial data in your dealings with external stakeholders, there are also massive advantages to be gained in your own internal pipeline management efforts. Want to learn how you can bridge your compliance gaps? Register for our Achieving PHMSA Compliance in the New Digital Era Webinar References Pipeline Safety: Regulatory Reform for Hazardous Liquid Pipelines, Federal Register, Pipeline and Hazardous Materials Safety Administration, 2020, p.7 Pipeline Safety: Regulatory Reform for Hazardous Liquid Pipelines, Federal Register, Pipeline and Hazardous Materials Safety Administration, 2020, p.13